1 Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

FINAL DRAFT STAFF REPORT 

Rule 4605 (Aerospace Assembly and Component Coating Operations) 

June 16, 2011 

Prepared by: Katy Linebach, Air Quality Specialist 

 Anna Myers, Air Quality Specialist 

 Koshoua Thao, Senior Air Quality Specialist 

Reviewed by: Stanley Tom, Senior Air Quality Engineer 

 John Hejde, Air Quality Inspector 

 Dan Barber, Supervising Air Quality Specialist 

 George Heinen, Supervising Air Quality Engineer 

Errol Villegas, Strategies and Incentives Manager 

 Samir Sheikh, Director of Strategies and Incentives 

I. SUMMARY 

The purpose of this rule development project is to amend the San Joaquin Valley’s Air 

Pollution Control District (District) September 2007 version of Rule 4605 (Aerospace 

Assembly and Component Coating Operations). On July 17, 2009, EPA made the 

following action: 

The submitted changes to Rule 4605 are largely administrative and clarify the 

SIP rule. The rule largely fulfills the relevant CAA [Clean Air Act] §110 and 

part D requirements, but the deficiencies discussed [...] preclude full SIP 

approval. We do not believe the deficiencies undermine emission 

reductions claimed for the Rule by the district. EPA staff recommends a 

simultaneous limited approval and limited disapproval of Rule 4605 

pursuant to CAA §110 (k)(3) and §301 (a) (EPA TSD, 4)

This action was published in Federal Register Vol 75, No.16 as 40 CFR Part 52 on January 

26, 2010. A copy of this Federal Register publication is included as Appendix D of this Staff 

Report. 

Pursuant to §179 of the CAA, unless the deficiency identified by EPA has been corrected 

and approved into the State Implementation Plan (SIP) within 18 months after the 

disapproval, one, or more sanctions shall be imposed, as selected by the EPA, until EPA 

determines that the State has come into compliance. The sanctions available to the EPA 

are as follows: 
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1. Highway Sanctions 

EPA may impose prohibitions, applicable to a nonattainment area, on the approval 

by the Secretary of Transportation of any projects or the awarding by the 

Secretary of any grants, under title 23 other than projects or grants for safety. 

2. Offsets 

In applying the emissions offset requirements of §7503 of this title to new or 

modified sources or emissions units for which a permit is required under this 

part, the ratio of emission reductions to increased emissions shall be at least two 

to one. 

The purpose of this rule-amending project is to correct the rule deficiency of Rule 4605 as 

cited by EPA, and to clarify the compliance schedule and methods by adding administrative 

language. These amendments are based on guidance received from EPA’s limited 

approval and limited disapproval Technical Support Document (TSD) issued in June 2009 

(Appendix E). 

A. Background 

Rule 4605 was originally adopted December 1991 and was last amended in September 

2007. On July 17, 2009, EPA evaluated Rule 4605 for meeting Reasonably Available 

Control Technology (RACT) requirements and determined the rule was deficient since the 

rule did not include emission limits pursuant to a 1997 Control Techniques Guideline (CTG) 

Document for the Control of Volatile Organic Compound Emissions from Coating Operations 

at Aerospace Manufacturing and Rework Operations (EPA-453/R-97-004). This evaluation 

resulted in a limited approval/limited disapproval of Rule 4605, published on January 26, 

2010 and started an 18 month sanction clock requiring the District to address the deficiency. 

The limited disapproval, detailed in the EPA Technical Support Document (TSD), identified 

coating categories that should be incorporated into the rule and a few other minor 

administrative changes in order for the rule to satisfy RACT requirements. 

The CTG contains content limits and control techniques to reduce VOC emissions from 

coatings and solvents used in the aerospace industry. The purpose of this rule 

development project is to amend the District’s Rule 4605 (Aerospace Assembly and 

Component Coating Operations) to incorporate the 17 new VOC coating limits. The 

District will also address two existing coating categories in Rule 4605 that are currently 

higher than the applicable limits in the CTG. 

B. Rule Development Process 

As guidelines for amending Rule 4605 to incorporate the 19 VOC coating limits, District 

staff reviewed the CTG for this source category, the 2007 Ozone Plan, rules in other air 

districts, and Federal and State regulations. Staff also conducted literature and internet 
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research when evaluating the 19 CTG limits for control of VOC emissions from coating 

operations at aerospace manufacturing and rework operations. Staff developed a survey 

for sources to inform the District as to the extent that these 19 new CTG limits would affect 

their business. Over two-thirds of the surveys were returned and most sources marked 

that they are currently using compliant coatings or that compliant coatings are available for 

them to use. District staff worked closely with those sources that indicated that they might 

be affected by the new limits. 

The proposed amendments to Rule 4605 and the Final Draft Staff Report were published 

and made available to affected sources and interested parties for review prior to a public 

hearing by the Governing Board. District staff welcomes public participation and invites 

the public to submit comments on this project. Comments received from affected source 

operators and interested parties will be evaluated and incorporated into the proposed 

amendments to the rule, as appropriate. The Receive and File date for this rule 

development project was held on May 19, 2011. The public hearing to consider adoption 

of the proposed amendments to Rule 4605 by the District Governing Board is scheduled 

for June 16, 2011. 

II. DISCUSSION 

A. Existing Rule 4605 

District Rule 4605, recently amended on September 20, 2007, sets VOC content limits for 

coatings, adhesives, and other related VOC-containing materials for coating operations 

related to aerospace assemblies and components. The flushing of jet or rocket engines 

using any solvent other than trichloroethylene is exempt. Aerospace assembly and 

component coating operations using less than four gallons per day of VOC-containing 

products are exempt as are other coatings or adhesives. Materials used in laboratories 

associated with research and development, quality control, or production testing are 

exempt from VOC content limits. There is also a limited exemption from application 

equipment standards. VOC emissions are 50% controlled compared to uncontrolled 

emissions. The current rule can be accessed on-line at: 

http://www.valleyair.org/rules/currntrules/r4605.pdf . 

B. CTG for Aerospace Coating 

Since the United States Environmental Protection Agency (EPA) and the California Air 

Resources Board (ARB) classified the San Joaquin Valley Air Basin (SJVAB) as a serious 

and severe non-attainment area for federal and state ozone standards, the state 

implementation plans (SIPs) must include reasonably available control measures (RACM), 

including RACT, for sources of emissions. CCA §183 (e) requires EPA to regulate VOC 

emissions from consumer and commercial products. CAA §182(b)(2) provides that, for 

certain nonattainment areas, States must revise their SIPs to include RACT for sources of 

VOC emissions covered by a CTG document issued between November 15, 1990 and the 
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date of attainment. CAA §183(e) directs EPA to list regulation for those categories of 

products that account for at least 80 percent of the VOC emissions, on a reactivityadjusted basis, from consumer and commercial products in areas that violate the national 

ambient air quality standards (NAAQS) for ozone (i.e., ozone nonattainment areas). 

Aerospace Coatings is included in the list of consumer and commercial products that are 

subject to EPA regulation. 

The CTG for control of VOC emissions from coating operations at aerospace 

manufacturing and rework operations applies to all manufacturing facilities that produce an 

aerospace vehicle or component and all facilities that rework or repair these aerospace 

products that are located in marginal, moderate, serious or severe ozone nonattainment 

areas that has the potential to emit greater than or equal to 25 tons/year of VOC, and 

greater than or equal to 10 tons/year of VOC for extreme ozone nonattainment areas The 

CTG may also include specialized shops that meet the definition of a major source and 

the definition of an aerospace manufacturing or rework facility. Operations and activities 

that are not subject to this CTG include the following: 

• Manufacturing or rework operations involving space vehicles, 

• Rework operations performed on antique aerospace vehicles or 

components, and 

• Cleaning and coating of aerospace components and vehicles for research 

and development, quality control, laboratory testing, or electronic parts and 

assemblies. (Cleaning and coating of completed assemblies are not 

excluded from requirements.) 

The CTG provides a list of specialty coatings with VOC content limits for aerospace 

components and vehicles. EPA considers the CTG to be presumptive RACT standards 

(63FR 15015). For the other air district’s standards that are more stringent than the CTG, 

the standards are considered Best Available Control Retrofit Technology (BARCT) and 

may be considered by the District in a separate rule making action in the future. 

The District has already incorporated the VOC coating limits for most of the specialty 

coating types into Rule 4605 during previous rulemaking. Rule 4605 is currently more 

stringent than the CTG limits for 34 specialty coatings and has 9 categories that are 

equivalent to the CTG limits. By implementing the remaining CTG limits, Rule 4605 will 

overall, be more stringent than other air district’s rule for aerospace assembly and 

component coating operations. 

C. EPA Evaluation of Rule 4605 

EPA used the following memoranda, guidance, and statute to review the submitted rule to 

evaluate compliance with RACT requirements of CAA §182(b)(2): 
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• SJVAPCD’s 2009 RACT SIP Demonstration (April 16, 2009); 

• EPA’s control Technique Guideline (CTG) titles, “Surface coating Operations at 

Aerospace Manufacturing & Rework Operations” (EPA-453/R-97-004, 

December 1997); 

• “Preamble, Final Rule to Implement the 8-hour Ozone National Ambient air 

Quality Standard” (70 FR 71612, November 29, 2005) 

• Letters from William T. Hartnett to Regional Air Division Directors, “RACT Qs & 

As – Reasonable Available Control Technology (RACT) Questions and 

Answers,” (May 18, 2006); and 

• Other state and Local rules for this category. 

 

EPA used the following memoranda, guidance, and statute to review the submitted rule 

to evaluate compliance with CAA §110(a)(2)(A) requirement for enforceability: 

• The Bluebook (“Issues Relating to VOC Regulation Cutpoints, Deficiencies, 

and Deviations,” EPA, May 25, 1988); 

• The Little Bluebook (“Guidance Document for Correcting Common VOC & 

Other Rule Deficiencies,” EPA Region 9, August 21, 2001); and 

• “State Implementation Plans, General Preamble for the Implementation of 

Title I of the Clean Air Amendments of 1990” (57 FR 13498, April 16, 1992). 

D. EPA Recommendations 

On January 26, 2010, EPA published a limited approval and limited disapproval of 

revisions to the District portion of the California SIP. This action was proposed in the 

Federal Register on July 17, 2009 regarding VOC emissions from aerospace assembly 

and component coating operations. Under authority of the CAA, as amended in 1990, 

this action simultaneously approves local rules that regulate these emission sources 

and directs California to correct rule deficiencies. 

EPA finalized a limited approval of the submitted rule, as authorized in §110(k)(3) and 

§301(a) of the CAA; EPA also simultaneously finalized a limited disapproval of a 

portion of the rule. Because of the limited disapproval, sanctions will be imposed on 

the District unless EPA approves subsequent SIP revisions that correct the rule 

deficiencies within 18 months of the effective date of this action. These sanctions will 

be imposed under §179 of the CAA according to 40 CFR 52.31. In addition, EPA must 

promulgate a federal implementation plan (FIP) under §110(c) unless EPA approves 

subsequent SIP revisions that correct the rule deficiencies within 24-months of the 

effective date of this action. Note that EPA’s final limited disapproval does not prevent 

the District from enforcing the rule. 

The Technical Support Document for the Notice of Proposed Rulemaking identifies 

that the current rule does not include 17 specialty VOC coating limits identified in the 

CTG and has two other specialty VOC coating limits with limits lower than the CTG 
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VOC coating limits. EPA also recommends including the full title of the ASTM methods 

in Section 6.2 and stating that a violation determined by either test method shall 

constitute a violation of the rule. 

The previously mentioned specialty VOC coating limits are a rule deficiency because 

the District has not demonstrated that any of the CTG limits are infeasible in the San 

Joaquin Valley or otherwise adequately demonstrated that Rule 4605 implements 

RACT consistent with CAA §180(b)(2). 

E. Summary of Amendments to Rule 4605 

The amendments to Rule 4605 will fulfill the requirements of the Control Technology 

Guidance (CTG) document, as well as fulfill the changes necessary for EPA to find Rule 

4605 RACT. These changes are based on guidance received from EPA’s limited approval 

and limited disapproval technical support document issues in June 2009. 

Section 3.0 Definitions 

Definitions for the following coatings were added to the rule: 

Ablative 

Bearing Coating 

Caulking and Smoothing Compounds 

Chemical Agent Resistant Coating 

Electromagnetic Interference Coating 

Intermediate Release Coating 

Lacquer 

Metalized Epoxy Coating 

Mold Release 

Part Marking Coating 

Rocket Motor Nozzle Coating 

Screen Print Ink 

Silicone Insulation Material 

Specialized Function Coating 

Thermal Control Coating 

Topcoat (Epoxy Polyamide) 

Wet Fastener Installation Coating 

These definitions were added to the rule to provide clarity on the new coatings types added, 

based on the need to incorporate all CTG coatings required. 

Section 5.0 Requirements 
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This section was amended to incorporate the CTG requirements and VOC limits. Table 3 

details the coatings and limits that were changed in the rule. 

Table 3: Coating types and VOC limits to meet CTG Requirements 

Coating Type to add to the Rule CTG Limit (g/L) 

Ablative 600 

Bearing Coating 620 

Caulking and Smoothing Compounds 850 

Chemical Agent Resistant Coating 550 

Electromagnetic Interference Coating 800 

Intermediate Release Coating 750 

Lacquer 830 

Table 3: Coating types and VOC limits to meet CTG Requirements 

(continued) 

Metalized Epoxy Coating 740 

Mold Release 780 

Part Marking Coating 850 

Rocket Motor Nozzle Coating 660 

Screen Print Ink 840 

Silicone Insulation Material 850 

Specialized Function Coating 890 

Thermal Control Coating 800 

Topcoat (Epoxy Polyamide) 660 

Wet Fastener Installation Coating 675 

Existing Coating Type with new lower VOC Limits

Sealant (Extrudable/Rollable/Brushable) 280 

Sealant (Fastener) 600 

A new effective date of January 1, 2013 is included in Table 1 of Section 5.0. This date is to 

allow time for sources to come into compliance with the new coating categories and limits 

that previously were not included in the rule. Many facilities keep stock on site, so time to 

use current product is necessary before the implementation of new coating VOC limits. 

The new coating limits in Table 1 include exemptions for coatings that are considered 

Department of Defense (DoD) “classified” coatings or coatings that are used on space 

vehicles. These two categories were added because of the exemptions provided on page 4-

3 of the 1997 CTG (Attached in Appendix A) and also 40 C.F.R. Appendix A to Subpart GC 

of Part 63 – Specialty Coating Definitions. DoD classified coatings and space vehicle 

coatings are listed as exempt coatings. 

Staff research revealed a local DoD facility that currently requires a higher VOC limit for a 

specific coating for a vehicle in use at their facility. Because of the CTG exemption for DoD 

coatings, this facility will be under the exemption from the new limit level for that coating and 
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will be able to comply with the rule. In order to prevent a rule relaxation, the DoD classified 

and space vehicle coatings will have to comply with VOC limits that are currently in place. 

Section 6.0 Administrative Requirements 

Section 6.5 has been amended to update the test methods for new requirements and the 

names of the mentioned test methods. This incorporates a change requested by EPA in 

the Technical Support Document. 

F. Global Climate Change and Greenhouse Gases Impacts 

The California Global Warming Solutions Act of 2006 (AB 32) created a comprehensive, 

multi-year program to reduce greenhouse gas (GHG) emissions in California, with the 

overall goal of restoring emissions to 1990 levels by the year 2020. In the coming years, 

the Air Resources Board (ARB) and the Legislature will be developing policies and 

programs to implement AB 32. The District believes that the evidence and the rationale 

that climate change is occurring is compelling and convincing. In addition to the long-term 

consequences of climate change, the District is concerned with the potential ramifications 

of more moderate but imminent changes in weather patterns. The Valley depends heavily 

on agriculture for its economy and has developed agricultural practices based on the last 

several decades of weather patterns. Unanticipated and large fluctuations in these 

patterns could have a devastating effect on the Valley’s economy. 

While there are many win-win strategies that can reduce both GHG and criteria/toxic 

pollutant emissions, when faced with situations that involve tradeoffs between the two, 

District staff believes that the more immediate public health concerns that may arise from 

an increase in criteria or toxic pollutant emissions should take precedence. The San 

Joaquin Valley Air Pollution Control District’s Governing Board adopted the Climate 

Change Action Plan (CCAP) in August 2008. For California Environmental Quality Act 

(CEQA) requirements, one of the goals of the CCAP is to establish District processes for 

assessing the significance of greenhouse gas impacts. The District has developed a policy 

and guidance for addressing greenhouse gases under CEQA. 

Adoption of the proposed amendments would lower VOC limits from coatings and solvents 

used in the aerospace industry and two specialty coating categories in Rule 4605. There 

are no foreseeable changes in operating practices resulting from implementation of these 

changes that would result in increased GHG emissions. Therefore, the District concludes 

that this rule development project would have a less than cumulative impact on global 

climate change. 

III. ANALYSIS 

A. Emissions and Emissions Reductions 
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According to the District’s 2007 Ozone Plan, the source category for Aerospace Assembly 

and Component Coating Operations (S-SOL-7) was not recommended as a control 

measure for VOC reduction and no additional reductions were available. The District staff 

is seeking to implement the 19 CTG limits as mentioned above. Since the federal CAA 

requires ozone nonattainment areas to implement RACT and the CTGs promulgated by 

EPA constitute RACT requirements, at a minimum, District staff is compelled to 

incorporate the CTG standards into Rule 4605. 

The ARB emissions inventory shows VOC emissions of 0.02 tons of VOC per day for this 

industry. Research of the District’s permit database has indicated that there are 14 

facilities that are currently subject to Rule 4605, with 12 currently operating. The District 

has previously employed more stringent methods than the CTG to achieve emissions 

reductions, such as the more stringent exemption limits in Section 4.4.1 of the rule. 

However, staffs evaluation has found that Valley operators will not be significantly 

impacted as they do not use coatings subject to the new categories, or can use readily 

available coatings compliant with the new categories. 

B. Cost Effectiveness Analysis 

Pursuant to California Health & Safety Code Section 40920.6(a), the District is required to 

analyze the cost effectiveness of new rules or rule amendments that implement Best 

Available Retrofit Control Technology (BARCT) or all feasible measure. The proposed 

amendments to Rule 4605 would add federal RACT requirements but not BARCT, and are 

therefore not subject to the cost effectiveness analysis mandate. 

C. Socioeconomic Analysis 

Pursuant to California Health & Safety Code Section 40728.5 (a) an assessment of the 

socioeconomic impacts is not required for any rule or regulation that only adopts a 

requirement that is substantially similar to, or is required by state or federal statute, 

regulation, or applicable formal guidance, such as a federal CTG. Since the proposed 

amendments to Rule 4605 implement the CTG standards mandated by the federal Clean 

Air Act, a socioeconomic impact analysis is not required. 

D. Environmental Impact Analysis 

Pursuant to the California Environmental Quality Act (CEQA), staff investigated the likely 

environmental impacts of the proposed amendments to Rule 4605. Adoption of the 

proposed amendments would lower VOC limits from coatings and solvents used in the 

aerospace industry and two specialty coating categories in Rule 4605 to match those 

specified in the CTG. There are no foreseeable changes in operating practices resulting 

from implementation of these changes that would impact environmental resources, including 

than air quality. Therefore, staff concludes that there is no substantial evidence in the whole 

record before the District that the proposed amendments would cause any adverse 
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environmental effects. The District finds that the project is exempt per the general rule that 

CEQA applies only to projects which have the potential for causing a significant effect on the 

environment (CCR §15061(b)(3)). For these reasons, staff is proposing to file a Notice of 

Exemption upon Board adoption of the proposed amendments to Rule 4605. 

E. Rule Consistency Analysis 

Pursuant to CH&SC §40727.2, District staff has prepared a rule consistency analysis that 

compares the elements of amendments with the corresponding elements of other District 

rules, federal regulations and guidelines that apply to the same source category or type of 

equipment. District staff found that the proposed amendments and requirements of this 

rule would not conflict with federal rules, regulations, or policies covering similar stationary 

sources. The rule consistency analysis is presented in Appendix B of the Final Draft Staff 

Report. Based on the updated analysis, District staff found that the proposed amendments 

to Rule 4605 would not conflict with federal rules, regulations, or policies covering similar 

stationary sources. 

F. RACT Analysis 

CAA §182(b)(2) states that ozone attainment plans shall assure that RACT for VOC is 

applied at certain sources. A RACT analysis requires an examination of a rule against 

Federal rules, regulations, and technology guidelines as well as comparing it against rules 

from other air districts in California. On April 16, 2009, the District adopted its “2009 

RACT SIP,” which provides the District’s demonstration that RACT is implemented for all 

appropriate activities. In the RACT SIP, District Rule 4605 was compared to federal and 

state regulations and guidance in Chapter 4: Rule Analysis. EPA disapproved part of Rule 

4605 in June 2009 because of the analysis not adequately demonstration the 

implementation of RACT. With the incorporated amendments to the rule, District Rule 

4605 will satisfy RACT requirements for aerospace assembly and component coating 

operations. 

 

IV. REFERENCES 

1. EPA CTG for Control of Volatile Organic Compound Emissions from Coating 

Operations at Aerospace Manufacturing and Rework Operations (EPA 453/R-97-

004), December 1997. 

2. EPA Revisions to the California State Implementation Plan, San Joaquin Valley Air 

Pollution Control District, Proposed Rule, (EPA-R09-OAR-2009-0475), June 30, 

2009 

2. EPA Technical Support Document for EPA’s Proposed Rulemaking for the 

California State Implementation Plan, Rule 4605, Aerospace Assembly and 

Component Coating Operations, June 2009 
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3. SCAQMD Rule 1124 Final Staff Report, August 2001

4. SCAQMD Rule 1124 Final environmental Assessment, August 29, 2001 

6. SJVAPCD RACT SIP Analysis, Chapter 4: Rule Analysis, April 4, 2009, pg. 196 – 

205 

7. 40 C.F.R. Appendix A to Subpart GG of Part 63 National Emission Standards for 

Hazardous Air Pollutants for Source Categories – Specialty Coating Definitions, 

http://law.justia.com/cfr/title40/40-10.0.1.1.1.7.18.16.10.html 
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